Case Digest (G.R. No. 141011) Core Legal Reasoning Model
Facts:
In the case of Citytrust Banking Corporation (now Bank of the Philippine Islands) vs. Isagani C. Villanueva (G.R. No. 141011), consolidated with Isagani C. Villanueva vs. Citytrust Banking Corporation (G.R. No. 141028), the events leading to the legal dispute began in February 1984 when Isagani C. Villanueva opened both a savings account and a current account with Citytrust Banking Corporation, both assigned specific account numbers. On May 21, 1986, Villanueva deposited funds in his savings account but lacked a checkbook for payments. He requested a new checkbook from a bank representative and, unable to recall his current account number, sought assistance. The representative erroneously provided the account number of another client with a similar name.
On June 17, 1986, he received the checkbook and issued a check for P50,000 to Kingly Commodities Traders. However, the check was dishonored on June 23 due to insufficient funds and later for reasons including an alleged stop-p
Case Digest (G.R. No. 141011) Expanded Legal Reasoning Model
Facts:
- Opening of Accounts: In February 1984, Isagani C. Villanueva (VILLANUEVA) opened a savings account and a current account with Citytrust Banking Corporation (BANK), assigned account numbers 1-033-02337-1 and 33-00977-5, respectively, with an automatic transfer arrangement.
- Request for New Checkbook: On 21 May 1986, VILLANUEVA deposited money into his savings account and requested a new checkbook. He filled out a requisition slip but could not remember his current account number. A BANK customer service representative assured him she would supply the account number from the BANK's records.
- Error in Account Number: Pia Rempillo, another BANK employee, saw the requisition slip and mistakenly copied the account number of another depositor with the same name, "Isagani Villanueva," but with a different middle initial (Account No. 33-00446-3).
- Issuance of Check: On 17 June 1986, VILLANUEVA received the new checkbook and issued Check No. 396701 for P50,000 payable to Kingly Commodities Traders and Multi Resources, Inc. (Kingly Commodities). He deposited P31,600 into his savings account, bringing his total deposits to P51,304.91.
- Dishonor of Check: On 23 June 1986, the check was dishonored due to "insufficiency of funds" and "disparity in signature." VILLANUEVA was assured by the BANK's Operations Manager, Maritess Gamboa, that the check would be honored upon re-deposit.
- Second Dishonor: On 26 June 1986, the check was dishonored again due to "insufficiency of funds" and a "stop-payment order" VILLANUEVA never issued. The BANK later discovered the error in the account number and issued a manager's check to Kingly Commodities to resolve the issue.
- Demand for Damages: On 30 June 1986, VILLANUEVA demanded P70,000 for actual damages and P2 Million for moral and other damages from the BANK. The BANK apologized but blamed VILLANUEVA for not providing his account number.
- Filing of Complaint: VILLANUEVA filed a complaint for damages, alleging breach of contract and gross negligence by the BANK, seeking P240,000 in actual damages, P2 Million in moral damages, and P500,000 in exemplary damages, among others.
- Trial Court Decision: The trial court dismissed the complaint, finding VILLANUEVA negligent for not providing his account number and failing to verify the new checkbook's account number. The BANK's negligence was deemed contributory but not the proximate cause of the damages.
- Court of Appeals Decision: The Court of Appeals reversed the trial court, holding the BANK responsible for the error and awarding VILLANUEVA P100,000 in moral damages and P50,000 in attorney's fees. However, it denied compensatory damages.
Issues:
- Whether the BANK's negligence in assigning the wrong account number was the proximate cause of the dishonor of VILLANUEVA's check.
- Whether VILLANUEVA is entitled to compensatory damages for alleged loss of profits.
- Whether VILLANUEVA is entitled to moral damages and attorney's fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court reversed the Court of Appeals' decision and reinstated the trial court's dismissal of the complaint and counterclaim. No costs were awarded.